Citi CONCIERGE PRIVACY NOTICE Last updated as of: April 2022
Thank you for using Citi Concierge. The entity providing the Service of Citi Concierge is Aspire Lifestyles Pte Ltd, a company operating under the laws of Singapore, located at 51 Changi Business Park Central 2, The Signature #03-02, Singapore 486066. Citi Concierge (the "Service ") is a concierge service intended to enhance your Citi cardholder experience.
This privacy notice for Citi Concierge ("Company," "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"). As used in this Privacy Notice the term ‘Citi Concierge’ includes the platform and any other Citi Concierge channels operated by Citi or Aspire Lifestyles that reference this Privacy Notice. Citi Concierge uses information obtained from Citi Mobile App (where you access the service) and from you, in connection with your use of Citi Concierge, for our own internal analysis to make the platform more interesting and to provide better services to you.
This Privacy Notice does not cover the collection and use of your Personal Information by third parties, including third party websites or applications, by your Card issuers (e.g., your bank), or any other information or communications that may outside the scope of the services except as otherwise provided herein.
This Privacy Notice is specific to the Citi Concierge services. Further details of Citi’s use of personal information more generally and Citi’s Global Privacy Notice are available at https://www.citibank.com.sg/gcb/footer/privacy.htm?lid=SGENCBGPIFOTLPrivacy
A special note about minors
Citi Concierge is not available to minors below the legal age of majority. By using the Services, you represent that you are above the legal age of majority or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services.
NOTICE
This privacy statement is provided in a layered format so you can review the specific areas set out below:
Personal Information We May Collect How We May Use Your Personal Information How We Share Your Personal Information Cookies Your Rights and Choices How We Protect Your Personal Information Data Transfers Data Retention Features and Links to Other Websites How to Contact Us Updates to This Privacy Notice
1. Personal Information We Collect
In connection with your use of the Site and Services, we may also collect certain Personal Information such as your first and last name, card type, email address, mobile phone number, the location information you provide, information for booking requests and information about your mobile device and your Site usage data. We collect Personal Information about you from the following sources: (i) directly from you through the Site feedback function; and (ii) through your mobile phone such as mobile device identifiers like the IMEI number, MAC address, and IP address. We may also receive your geo-location information if you consent to our use of GPS or geo-location services within the Site.
2. How We May Use Your Personal Information
We may use the Personal Information we obtain about you:
Where you have given us consent to fulfill Concierge requests submitted by you through the Sites or by calling our Concierge; To provide customer service and respond to your inquiries in relation to your use of the Site or Services, and to notify you about any changes to our service; Provide, administer, and communicate with you about products, services and promotions (including contests, sweepstakes, programs and other offers), including the display of customized content and advertising; Operate, evaluate, and improve our business (including by developing new products and services; managing our communications; determining the effectiveness of our advertising; analyzing our products, services, and websites; facilitating the functionality of our websites; and assisting third parties in the provision of products or services that you request from third parties); Administer, support, improve, optimize, and develop the Site or Services; Monitor the use of and improve our interactive assets; Perform data analyses to determine, among other measurements, business performance, number of registrants, channels, transaction spend and site performance; Perform auditing, research, and analysis in order to maintain, protect and improve our services; Use your information on an aggregated basis (not personally identifiable) to do such things as operate our site, enhance our site, and deliver messages. We may disclose aggregated information about our users, but that information contains no Personal Information. We may also use your Personal Information to notify you of the latest services and our exciting new offers if you have either requested marketing communications from us or consented to receive marketing communications such as the Concierge Service newsletter. You may opt out from receiving marketing communications at any time by following the procedure to ‘unsubscribe’ that is specified in any marketing email that you receive.
Where we need to collect personal data, and you fail to provide that data when requested, we may not be able to fulfil your request or enquiries and provide our services (for example, to provide you with our Concierge services) or provide you with any support you are seeking from us. In this case, we will notify you if this is the case at the time
3. How We Share Your Personal Information
We do not sell or otherwise disclose Personal Information we collect about you, except as described herein or otherwise disclosed to you at the time the data is collected to fulfill your Concierge service requests.
We may share your Personal Information with third parties, but only to perform the services requested by you in connection with your use of the Site and Concierge service. For example, we will share your Personal Information required to complete a dining reservation with a restaurant in order to fulfill your reservation request. When you use the service to make a reservation with a third party, you authorize us to disclose the information required by such third party to complete the booking. These third parties are not controlled by Aspire and Personal Information disclosed to them is subject to the applicable third party’s privacy policy and security practices.
We may disclose your Personal Information about you to your issuing bank, if applicable, and its service providers in connection with the Concierge service for the purpose of addressing your requests and/or inquiries.
We may share your Personal Information with affiliates (which includes any of our subsidiaries).
We also may share your Personal Information with our service providers who perform services on our behalf. We do not authorize these service providers to use or disclose such data except as necessary to perform certain services on our behalf or comply with legal requirements. We require these service providers by contract to appropriately safeguard the privacy and security of Personal Information they process on our behalf.
We also may disclose your Personal Information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.
4. Cookies
We use a feature of your browser called a “cookie” to assign a unique number that automatically identifies your computer when you visit the site.
A cookie is a piece of data stored on your hard drive containing information about you. For instance, by setting a cookie on our site, you would not have to log in a password more than once, thereby saving time while on our site. If you reject the cookie, you may still use our site, but you may be limited in some areas of our site or may have to enter passwords or identifying information more than once. We may collect Personal Information from you at other points on our site that state that Personal Information is being collected. In the event of a complaint, we may also receive Personal Information about you from other users or third parties who may communicate information to us about you in relation to that complaint.
5. Your Rights and Choices
Subject to applicable law, you have the right to request access to and receive information about the Personal Information we maintain about you, to update and correct inaccuracies in your Personal Information, and have the information blocked or deleted, as appropriate. The right to access Personal Information may be limited in some circumstances by local law. To update your preferences, ask us to remove your Personal Information or submit an access request, please contact us as specified below under Section 11 “How to Contact Us”.
You may choose not to provide Personal Information. However, if you do not provide Personal Information when requested, you may not be able to benefit from the full functionality of the Site and/or we may not be able to provide you with relevant information, products and/or services.
6. How We Protect Personal Information
We restrict access to Personal Information about you to those employees who need to know that information to provide products or services to you. We maintain reasonable administrative, technical, and physical safeguards that comply with regulations to protect the Personal Information we have about you. We also take measures to destroy or permanently de-identify personal information when there is no longer a business need to keep the information. The types of measures we take vary with the type of information, and how it is collected and stored. Unfortunately, no data transmission can be guaranteed to be 100% secure. Thus, while we strive to protect your Personal Information, we cannot ensure or warrant the security of any data transmission.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. Data Transfers
We may transfer Personal Information to countries other than the country in which the data was originally collected. These countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your Personal Information to other countries, we will protect that information as described in this Privacy Notice.
To offer our services, we may need to transfer your personal information among several countries, including the United States. We comply with applicable legal requirements providing adequate safeguards for the transfer of personal information.
8. Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, any legitimate administrative or operational purposes, your requirements, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in connection with our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of your personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.
When it is no longer necessary to retain your personal data, we will securely delete or in some circumstances we may anonymize your personal data (so that it can no longer be linked with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Features and Links to Other Websites
Within our Site, you may choose to use certain features for which we partner with other entities or click on links to other websites or applications for your convenience and information. These features, which may include social networking and geographic location tools, and other websites, may operate independently from Us. They may have their own privacy notices or policies, which we strongly suggest you review. To the extent any features or linked websites you visit are not owned or operated by Us, we are not responsible for any content or use of the third parties’ sites or applications, or the privacy practices of such sites or applications.
10. How to Contact Us Regarding this Policy
You may contact us regarding this Policy via electronic communication or phone as set forth below:
Email: Privacy@aspirelifestyles.com
Phone: You may contact us using the Concierge Service contact number associated with your program, or by calling the Concierge Service phone number listed on the back of your credit card (if applicable).
We may need to collect information from you to verify your identity, and then we will respond within 30 days, or other legally mandated time frame, of receiving your Personal Information Request.
11. Updates to This Privacy Notice
This Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our Personal Information practices. We will post a prominent notice on the Site to notify you of any significant changes to our Privacy Notice and indicate at the top of the notice when it was most recently updated. Your continued use of the Site after any changes to the Privacy Notice (as notified on our website) constitutes your acceptance of the changes. Please review our Privacy Notice on our websites periodically to ensure that you are aware of any changes or updates.
We reserve the right to change this policy at any time by notifying users through its website, or other means, of the existence of a new privacy statement prior to the change becoming effective. This statement and the policies outlined herein are not intended to and do not create any contractual or other legal rights. We encourage you to periodically review this page for the latest information on our privacy practices.
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